VALSALA RAJ vs. THE ASSISTANT COMMISSIONER OF INCOME TAX

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WP(C)/17624/2020HC KeralaKLHC01044457202008 December 2020Bench: HONOURABLE MR. JUSTICE AMIT RAWAL19 pages
AI SummaryDismissed

What did the High Court hold?

The High Court of Kerala, considering the submissions of the Income Tax Department, held that no cause of action survived in the writ petitions. This was primarily because a fresh attachment order had been passed under Rule 48 of the Second Schedule of the Income Tax Act, 1961, during the pendency of the writ petitions, and after the assessment orders were passed. The court noted that the petitioners had appealed the assessment order and it was stayed. Consequently, the court found the writ petitions not maintainable at that stage and disposed of them. The petitioners were granted liberty to challenge any fresh order in accordance with law as and when a fresh cause of action arose. The court did not specifically decide on the validity of the original provisional attachment order beyond its expiry date or the implications of the amended Section 281B, as the subsequent attachment rendered the original issue moot.

What were the facts?

These three writ petitions (WP(C) Nos. 17591, 17624, and 17638 of 2020) were filed by Varun Raj, Valsala Raj, and Arun Raj Pillai, respectively, against the Assistant Commissioner of Income Tax and the Principal Commissioner of Income Tax (Central). The core issue revolves around the validity and duration of a provisional attachment order issued under Section 281B of the Income Tax Act, 1961. The petitioners' properties were initially attached in September 2018 for six months, with an extension granted on October 31, 2019, which expired on April 30, 2020. Despite the expiry, the Sub-Registrar had not been informed of the non-existence of the attachment order, leaving the petitioners in uncertainty. The assessment orders were passed on March 18, 2020.

What were the issues?

1. Whether an order of provisional attachment issued under Section 281B of the Income Tax Act, 1961, prior to assessment, remains valid and in force after the expiry of the maximum period of two years, especially in light of amended provisions regarding its validity post-final assessment. Assessee's Contention: The petitioners argued that the provisional attachment order, which was extended until April 30, 2020, had expired. They also referred to the amended provision of Section 281B, stating that the validity of a provisional assessment order is sixty days after the passing of final assessment orders. Since the assessment orders were dated March 18, 2020, the attachment orders were no longer in existence, but the lack of communication from the Income Tax Department created a predicament. Revenue's Contention: The Income Tax Department submitted that during the pendency of the writ petitions, a fresh attachment order was issued under Rule 48 of the Second Schedule of the Income Tax Act, 1961, after the assessment order. They contended that although the petitioners had preferred an appeal and the assessment order was stayed, the writ petitions concerning the provisional attachment had become infructuous. The department stated that the petitioners' objections regarding the veracity of the assessment order could be adjudicated.

Which sections of the Income-tax Act were involved?

Section 281B

AI-generated summary — verify with the full judgment below

Heard together (3 matters)

WP(C).No.17591 OF 2020
WP(C).17624/2020
WP(C).17638/2020

Read from the judgment's own cause title. This page is filed under one of them.

IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE AMIT RAWAL TUESDAY, THE 08TH DAY OF DECEMBER 2020 / 17TH AGRAHAYANA, 1942 WP(C).No.17591 OF 2020(Y) PETITIONER: VARUN RAJ, AGED 32 YEARS, S/O. M. K. RAJENDRAN PILLAI, RAJAVALSAM, PANAGADU, KULANADA, PANDALAM P. O., PATHANAMTHITTA. BY ADVS. SRI.S.MUHAMMED HANEEFF SRI.M.H.ASIF ALI SMT.SHAIMA VAHAB RESPONDENTS: 1 THE ASSISTANT COMMISSIONER OF INCOME TAX AAYAKAR BHAVAN, KOLLAM, KERALA - 620 001. 2 THE PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL) I. S. PRESS ROAD, KOCHI - 682 031. BY ADV. SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI. JOSE JOSEPH, SC, FOR INCOME TAX THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 08.12.2020, ALONG WITH WP(C).17624/2020(C), WP(C).17638/2020(D), THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:

WP(C).No.17591 OF 2020 & con.cases -2- IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE AMIT RAWAL TUESDAY, THE 08TH DAY OF DECEMBER 2020 / 17TH AGRAHAYANA, 1942 WP(C).No.17624 OF 2020(C) PETITIONER: VALSALA RAJ, AGED 57 YEARS, W/O.M.K.RAJENDRAN PILLAI, RESIDING AT RAJAVALSOM, PANANGADU P.O., KULANADA, PANDALAM, PATHANAMTHITTA - 689 503. BY ADVS. SRI.S.MUHAMMED HANEEFF SRI.M.H.ASIF ALI SMT.SHAIMA VAHAB RESPONDENTS: 1 THE ASSISTANT COMMISSIONER OF INCOME TAX AAYAKAR BHAVAN, KOLLAM, KERALA - 620 001. 2 THE PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL) I.S.PRESS ROAD, KOCHI - 682031. BY ADV. SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI. JOSE JOSEPH, SC, FOR INCOME TAX THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 08.12.2020, ALONG WITH WP(C).17591/2020(Y), WP(C).17638/2020(D), THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:

WP(C).No.17591 OF 2020 & con.cases -3- IN THE HIGH COURT OF KERALA AT ERNAKULAM PRESENT THE HONOURABLE MR. JUSTICE AMIT RAWAL TUESDAY, THE 08TH DAY OF DECEMBER 2020 / 17TH AGRAHAYANA, 1942 WP(C).No.17638 OF 2020(D) PETITIONER: ARUN RAJ PILLAI, AGED 30 YEARS, S/O.M.K.RAJENDRAN PILLAI, RAJAVALSAM, PANAGADU, KULANADA, PANDALAM P.O., PATHANAMTHITTA - 689 503. BY ADVS. SRI.S.MUHAMMED HANEEFF SRI.M.H.ASIF ALI SMT.SHAIMA VAHAB RESPONDENTS: 1 THE ASSISTANT COMMISSIONER OF INCOME TAX, AAYAKAR BHAVAN, KOLLAM, KERALA -620 001. 2 THE PRINCIPAL COMMISSIONER OF INCOME TAX (CENTRAL) I.S.PRESS ROAD, KOCHI- 682031. BY ADV. SRI.P.K.RAVINDRANATHA MENON (SR.) BY SRI. JOSE JOSEPH, SC, FOR INCOME TAX THIS WRIT PETITION (CIVIL) HAVING BEEN FINALLY HEARD ON 08.12.2020, ALONG WITH WP(C).17591/2020(Y), WP(C).17624/2020(C), THE COURT ON THE SAME DAY DELIVERED THE FOLLOWING:

WP(C).No.17591 OF 2020 & con.cases -4- JUDGMENT [ WP(C).17591/2020, WP(C).17624/2020, WP(C).17638/2020 ] Dated this the 8th day of December 2020 The controversy involved in these writ petitions is whether the order of provisional attachment issued under Section 281B of the Income Tax Act, 1961 (hereinafter referred to as 'the Act', for short) before the assessment would be valid and in force after the expiry of maximum period of two years. 2. Learned counsel appearing on behalf of the petitioner submits that vide Ext.P13 in September, 2018 properties of the petitioners were attached for a period of six months and extended to another period of six months. The extension as per the last order was on 31.10.2019, expired on 30.04.2020. However, the Sub-Registrar has not been communicated regarding the non-existence of the attachment order. As per the amended provision of Section 281B, the validity of the provisional assessment

WP(C).No.17591 OF 2020 & con.cases -5- order would be of sixty days after the passing of the final assessment orders. In the instant case, assessment orders are dated 18.03.2020 and therefore, attachment orders are no longer in existence but there is no communication from the Income Tax Department and therefore, the petitioners predicament is in oblivion. 3. On the other hand, learned counsel appearing on behalf of the Income Tax Department submits that during the pendency of the writ petition, there was an attachment after the assessment order, under Rule 48, of Second Schedule of the Income Tax Act, 1961. Though the petitioners have preferred an appeal and order of assessment is stayed, writ petitions qua the provisional attachment is thus, rendered infructuous. Petitioners have already taken objections regarding the veracity of the assessment order impugned and the same can be adjudicated. On consideration of the submissions made by Mr.Jose Joseph, learned counsel for the Income Tax Department, no

WP(C).No.17591 OF 2020 & con.cases -6- cause of action survives in the writ petitions in view of the fact that as the attachment order has been passed under Rule 48 of the the Second Schedule of the Income Tax. Writ petitions are not maintainable at this stage and disposed of. Liberty is granted to the petitioners to challenge the order, if any, in accordance with law as and when fresh cause action arises. Sd/- AMIT RAWAL vv JUDGE

WP(C).No.17591 OF 2020 & con.cases -7- APPENDIX OF WP(C) 17591/2020 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDER IN RESPECT OF THE PETITIONER PASSED PROTECTIVELY DATED 18.03.2020 FOR THE ASSESSMENT YEAR 2012-13. EXHIBIT P2 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDER IN RESPECT OF THE PETITIONER PASSED PROTECTIVELY DATED 18.03.2020 FOR THE ASSESSMENT YEAR 2013-14. EXHIBIT P3 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDER IN RESPECT OF THE PETITIONER PASSED PROTECTIVELY DATED 18.03.2020 FOR THE ASSESSMENT YEAR 2014-15. EXHIBIT P4 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDER IN RESPECT OF THE PETITIONER PASSED PROTECTIVELY DATED 18.03.2020 FOR THE ASSESSMENT YEAR 2015-16. EXHIBIT P5 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDER IN RESPECT OF THE PETITIONER PASSED PROTECTIVELY DATED 18.03.2020 FOR THE ASSESSMENT YEAR 2016-17. EXHIBIT P6 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDER IN RESPECT OF THE PETITIONER PASSED PROTECTIVELY DATED 18.03.2020 FOR THE ASSESSMENT YEAR 2017-18. EXHIBIT P7 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDERS DATED 17.03.2020, IN RESPECT OF SHRI RAJENDRAN PILLAI PASSED SUBSTANTIVELY FOR THE ASSESSMENT YEAR 2012-13.

WP(C).No.17591 OF 2020 & con.cases -8- EXHIBIT P8 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDERS DATED 17.03.2020, IN RESPECT OF SHRI RAJENDRAN PILLAI PASSED SUBSTANTIVELY FOR THE ASSESSMENT YEAR 2013-14. EXHIBIT P9 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDERS DATED 17.03.2020, IN RESPECT OF SHRI RAJENDRAN PILLAI PASSED SUBSTANTIVELY FOR THE ASSESSMENT YEAR 2014-15. EXHIBIT P10 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDERS DATED 17.03.2020, IN RESPECT OF SHRI RAJENDRAN PILLAI PASSED SUBSTANTIVELY FOR THE ASSESSMENT YEAR 2015-16. EXHIBIT P11 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDERS DATED 17.03.2020, IN RESPECT OF SHRI RAJENDRAN PILLAI PASSED SUBSTANTIVELY FOR THE ASSESSMENT YEAR 2016-17. EXHIBIT P12 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDERS DATED 17.03.2020, IN RESPECT OF SHRI RAJENDRAN PILLAI PASSED SUBSTANTIVELY FOR THE ASSESSMENT YEAR 2017-18. EXHIBIT P13 A TRUE COPY OF THE ORDER BEARING NO.ACAPR8839E/281B/ACIT/CC/KLM/18-19 DATED 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.685/06 AND OTHER. EXHIBIT P13(a) A TRUE COPY OF THE ORDER BEARING NO.ACAPR8839E/281B/ACIT/CC/KLM/18-19 DATED 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.361/15. EXHIBIT P13(b) A TRUE COPY OF THE ORDER BEARING NO.ACAPR8839E/281B/ACIT/CC/KLM/18-19 DATED 17.09.18 PERTAINING TO PROPERTIES

WP(C).No.17591 OF 2020 & con.cases -9- OF THE PETITIONER COVERED BY DOCUMENT NO.1040/16. EXHIBIT P13(c) A TRUE COPY OF THE ORDER BEARING NO.ACAPR8839E/281B/ACIT/CC/KLM/18-19 DATED 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.IN-DL-26345648582334M. EXHIBIT P13(d) A TRUE COPY OF THE ORDER BEARING NO.ACAPR8839E/281B/ACIT/CC/KLM/18-19 DATED 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.2918/16. EXHIBIT P13(e) A TRUE COPY OF THE ORDER BEARING NO.ACAPR8839E/281B/ACIT/CC/KLM/18-19 DATED 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.2320/11 AND OTHER. EXHIBIT P13(f) A TRUE COPY OF THE ORDER BEARING NO.ACAPR8839E/281B/ACIT/CC/KLM/18-19 DATED 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.93/13. EXHIBIT P13(g) A TRUE COPY OF THE ORDER BEARING NO.ACAPR8839E/281B/ACIT/CC/KLM/18-19 DATED 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.949/10. EXHIBIT P13(h) A TRUE COPY OF THE ORDER BEARING NO.ACAPR8839E/281B/ACIT/CC/KLM/18-19 DATED 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.853/12. EXHIBIT P13(i) A TRUE COPY OF THE ORDER BEARING NO.ACAPR8839E/281B/ACIT/CC/KLM/18-19 DATED 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.889/10.

WP(C).No.17591 OF 2020 & con.cases -10- NO.ACAPR8839E/281B/ACIT/CC/KLM/18-19 DATED 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.693/14. EXHIBIT P13(k) A TRUE COPY OF THE ORDER BEARING NO.ACAPR8839E/281B/ACIT/CC/KLM/18-19 DATED 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.2069/16. EXHIBIT P13(l) A TRUE COPY OF THE ORDER BEARING NO.ACAPR8839E/281B/ACIT/CC/KLM/18-19 DATED 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.1635/14. EXHIBIT P13(m) A TRUE COPY OF THE ORDER BEARING NO.ACAPR8839E/281B/ACIT/CC/KLM/18-19 DATED 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.1060/10. EXHIBIT P13(n) A TRUE COPY OF THE ORDER BEARING NO.ACAPR8839E/281B/ACIT/CC/KLM/18-19 DATED 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.193/04. EXHIBIT P13(o) A TRUE COPY OF THE ORDER BEARING NO.ACAPR8839E/281B/ACIT/CC/KLM/18-19 DATED 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.585/16. EXHIBIT P13(p) A TRUE COPY OF THE ORDER BEARING NO.ACAPR8839E/281B/ACIT/CC/KLM/18-19 DATED 17.09.18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.977/16 AND OTHER. EXHIBIT P14 A TRUE COPY OF THE ORDER BEARING NO.DDIT/INV/KLM/MKR/17-18 DATED 03.10.17 PERTAINING TO PROPERTIES AT BANGALORE COVERED BY DOCUMENT NO.3826/2013-14.

WP(C).No.17591 OF 2020 & con.cases -11- EXHIBIT P14(a) A TRUE COPY OF THE ORDER BEARING NO.DDIT/INV/KLM/MKR/17-18 DATED 03.10.17 PERTAINING TO PROPERTIES AT BANGALORE COVERED BY DOCUMENT NO.2425/2006-07. EXHIBIT P14(b) A TRUE COPY OF THE ORDER BEARING NO.DDIT/INV/KLM/MKR/17-18 DATED 03.10.17 PERTAINING TO PROPERTIES AT BANGALORE COVERED BY DOCUMENT NO.6036/2008-09. EXHIBIT P15 THE ACKNOWLEDGMENT OF DECLARATION U/S 183 OF THE FINANCE ACT, 2016 WHICH INCLUDES THE DESCRIPTION OF THE PROPERTIES. EXHIBIT P16 THE DETAILS OF THE PAYMENT EFFECTED ON VARIOUS DATES BY THE PETITIONER AND OTHER FAMILY MEMBERS. EXHIBIT P17 DETAILS OF THE PAYMENT MADE BY THE PETITIONER AND HIS FAMILY MEMBERS SUBSEQUENT TO THE PAYMENTS MADE AS SHOWN IN EXT P16.

WP(C).No.17591 OF 2020 & con.cases -12- APPENDIX OF WP(C) 17624/2020 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDER IN RESPECT OF THE PETITIONER PASSED PROTECTIVELY DATED 18/03/2020 FOR THE ASSESSMENT YEAR 2012-13. EXHIBIT P2 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDER IN RESPECT OF THE PETITIONER PASSED PROTECTIVELY DATED 18/03/2020 FOR THE ASSESSMENT YEAR 2013-14. EXHIBIT P3 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDER IN RESPECT OF THE PETITIONER PASSED PROTECTIVELY DATED 18/03/2020 FOR THE ASSESSMENT YEAR 2014-15. EXHIBIT P4 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDER IN RESPECT OF THE PETITIONER PASSED PROTECTIVELY DATED 18/03/2020 FOR THE ASSESSMENT YEAR 2015-16. EXHIBIT P5 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDER IN RESPECT OF THE PETITIONER PASSED PROTECTIVELY DATED 18/03/2020 FOR THE ASSESSMENT YEAR 2016-17 EXHIBIT P6 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDER IN RESPECT OF THE PETITIONER PASSED PROTECTIVELY DATED 18/03/2020 FOR THE ASSESSMENT YEAR 2017-18. EXHIBIT P7 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDERS DT. 17/03/2020, IN RESPECT OF SRI.RAJENDRAN PILLAI, PASSED SUBSTANTIVELY FOR THE ASSESSMENT YEAR 2012- 13. EXHIBIT P8 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDERS DT. 17/03/2020, IN RESPECT OF SRI.RAJENDRAN PILLAI, PASSED SUBSTANTIVELY FOR THE ASSESSMENT YEAR 2013- 14.

WP(C).No.17591 OF 2020 & con.cases -13- EXHIBIT P9 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDERS DT. 17/03/2020, IN RESPECT OF SRI.RAJENDRAN PILLAI, PASSED SUBSTANTIVELY FOR THE ASSESSMENT YEAR 2014- 15. EXHIBIT P10 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDERS DT. 17/03/2020, IN RESPECT OF SRI.RAJENDRAN PILLAI, PASSED SUBSTANTIVELY FOR THE ASSESSMENT YEAR 2015- 16. EXHIBIT P11 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDERS DT. 17/03/2020, IN RESPECT OF SRI.RAJENDRAN PILLAI, PASSED SUBSTANTIVELY FOR THE ASSESSMENT YEAR 2016- 17. EXHIBIT P12 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDERS DT. 17/03/2020, IN RESPECT OF SRI.RAJENDRAN PILLAI, PASSED SUBSTANTIVELY FOR THE ASSESSMENT YEAR 2017- 18. EXHIBIT P13 A TRUE COPY OF THE ORDER BEARING NO.ACAPR8941B/281B/ACIT/CC/KLM/18-19 DT. 17/09/19 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.587/16. EXHIBIT P13(A) A TRUE COPY OF THE ORDER BEARING NO.ACAPR8941B/281B/ACIT/CC/KLM/18-19 DT. 17/09/18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.N-DL- 24269163089024M. EXHIBIT P13(B) A TRUE COPY OF THE ORDER BEARING NO.ACAPR8941B/281B/ACIT/CC/KLM/18-19 DT. 17/09/18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.182/2014 & OTHER. EXHIBIT P13(C) A TRUE COPY OF THE ORDER BEARING NO.ACAPR8941B/281B/ACIT/CC/KLM/18-19 DT. 17/09/18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT

WP(C).No.17591 OF 2020 & con.cases -14- NO.1593/2012. EXHIBIT P13(D) A TRUE COPY OF THE ORDER BEARING NO.ACAPR8941B/281B/ACIT/CC/KLM/18-19 DT. 17/09/18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.2483/2008 & OTHER. EXHIBIT P13(E) A TRUE COPY OF THE ORDER BEARING NO.ACAPR8941B/281B/ACIT/CC/KLM/18-19 DT. 17/09/18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.302/13 & OTHER. EXHIBIT P13(F) A TRUE COPY OF THE ORDER BEARING NO.ACAPR8941B/281B/ACIT/CC/KLM/18-19 DT. 17/09/18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.2122/88 & OTHER. EXHIBIT P13(G) A TRUE COPY OF THE ORDER BEARING NO.ACAPR8941B/281B/ACIT/CC/KLM/18-19 DT. 17/09/18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.1445/2009 & OTHER. EXHIBIT P14 A TRUE COPY OF THE BEARING NO.DDIT/INV/KLM/MKR/17-18 DT. 03/10/17 PERTAINING TO THE PROPERTIES AT BANGALORE COVERED BY DOCUMENT NO.3826/2013-14. EXHIBIT P14(A) A TRUE COPY OF THE ORDER BEARING NO.DDIT/INV/KLM/MKR/17-18 DT. 03/10/17 PERTAINING TO THE PROPERTIES AT BANGALORE COVERED BY DOCUMENT NO.2425/2006-07 & OTHER. EXHIBIT P14(B) A TRUE COPY OF THE ORDER BEARING NO.DDIT/INV/KLM/MKR/17-18 DT. 03/10/17 PERTAINING TO THE PROPERTIES AT BANGALORE COVERED BY DOCUMENT NO.6036/2008-09 & OTHER. EXHIBIT P15 THE ACKNOWLEDGMENT OF DECLARATION U/S 183 OF THE FINANCE ACT, 2016 WHICH INCLUDES THE DESCRIPTION OF THE PROPERTIES.

WP(C).No.17591 OF 2020 & con.cases -15- EXHIBIT P16 THE DETAILS OF THE PAYMENT EFFECTED ON VARIOUS DATES, BY THE PETITIONER AND OTHER FAMILY MEMBERS.

WP(C).No.17591 OF 2020 & con.cases -16- APPENDIX OF WP(C) 17638/2020 PETITIONER'S/S EXHIBITS: EXHIBIT P1 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDER IN RESPECT OF THE PETITIONER PASSED PROTECTIVELY DATED 18/03/2020 FOR THE ASSESSMENT YEAR 2012-13. EXHIBIT P2 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDER IN RESPECT OF THE PETITIONER PASSED PROTECTIVELY DATED 18/03/2020 FOR THE ASSESSMENT YEAR 2013-14. EXHIBIT P3 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDER IN RESPECT OF THE PETITIONER PASSED PROTECTIVELY DATED 18/03/2020 FOR THE ASSESSMENT YEAR 2014-15. EXHIBIT P4 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDER IN RESPECT OF THE PETITIONER PASSED PROTECTIVELY DATED 18/03/2020 FOR THE ASSESSMENT YEAR 2015-16. EXHIBIT P5 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDER IN RESPECT OF THE PETITIONER PASSED PROTECTIVELY DATED 18/03/2020 FOR THE ASSESSMENT YEAR 2016-17. EXHIBIT P6 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDER IN RESPECT OF THE PETITIONER PASSED PROTECTIVELY DATED 18/03/2020 FOR THE ASSESSMENT YEAR 2017-18. EXHIBIT P7 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDERS DT. 17/03/2020, IN RESPECT OF SRI.RAJENDRAN PILLAI, PASSED SUBSTANTIVELY FOR THE ASSESSMENT YEAR 2012- 13. EXHIBIT P8 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDERS DT. 17/03/2020, IN RESPECT OF SRI.RAJENDRAN PILLAI, PASSED SUBSTANTIVELY FOR THE ASSESSMENT YEAR 2013- 14.

WP(C).No.17591 OF 2020 & con.cases -17- EXHIBIT P9 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDERS DT.17/03/2020, IN RESPECT OF SRI.RAJENDRAN PILLAI, PASSED SUBSTANTIVELY FOR THE ASSESSMENT YEAR 2014- 15. EXHIBIT P10 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDERS DT.17/03/2020, IN RESPECT OF SRI.RAJENDRAN PILLAI, PASSED SUBSTANTIVELY FOR THE ASSESSMENT YEAR 2015- 16. EXHIBIT P11 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDERS DT.17/03/2020, IN RESPECT OF SRI.RAJENDRAN PILLAI, PASSED SUBSTANTIVELY FOR THE ASSESSMENT YEAR 2016- 17. EXHIBIT P12 A TRUE COPY OF THE RELEVANT PAGES OF THE ASSESSMENT ORDERS DT.17/03/2020, IN RESPECT OF SRI.RAJENDRAN PILLAI, PASSED SUBSTANTIVELY FOR THE ASSESSMENT YEAR 2017- 18. EXHIBIT P13 A TRUE COPY OF THE ORDER BEARING NO.AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17/09/18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.1564/2011. EXHIBIT P13(A) A TRUE COPY OF THE ORDER BEARING NO.AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17/09/18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.463/2016 & OTHER. EXHIBIT P13(B) A TRUE COPY OF THE ORDER BEARING NO.AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17/09/18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.194/1/10 & OTHER. EXHIBIT P13(C) A TRUE COPY OF THE ORDER BEARING NO.AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17/09/18 PERTAINING TO PROPERTIES OF THE

WP(C).No.17591 OF 2020 & con.cases -18- PETITIONER COVERED BY DOCUMENT NO.2425/2006-07. EXHIBIT P13(D) A TRUE COPY OF THE ORDER BEARING NO.AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17/09/18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.1585/2014. EXHIBIT P13(E) A TRUE COPY OF THE ORDER BEARING NO.AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17/09/18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.362/15. EXHIBIT P13(F) A TRUE COPY OF THE ORDER BEARING NO.AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17/09/18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.692/14. EXHIBIT P13(G) A TRUE COPY OF THE ORDER BEARING NO.AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17/09/18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.2979/2015 & OTHER. EXHIBIT P13(H) A TRUE COPY OF THE ORDER BEARING NO.AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17/09/18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.2778/15 & OTHER. EXHIBIT P13(I) A TRUE COPY OF THE ORDER BEARING NO.AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 13/09/18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.57/92 & OTHER. EXHIBIT P13(J) A TRUE COPY OF THE ORDER BEARING NO.AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17/09/18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.2423/15 & OTHER. EXHIBIT P13(K) A TRUE COPY OF THE ORDER BEARING NO.AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17/09/18 PERTAINING TO PROPERTIES OF THE

WP(C).No.17591 OF 2020 & con.cases -19- PETITIONER COVERED BY DOCUMENT NO.586/16 EXHIBIT P13(L) A TRUE COPY OF THE ORDER BEARING NO.AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17/09/18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.3387/13 & OTHER. EXHIBIT P13(M) A TRUE COPY OF THE ORDER BEARING NO.AHCPR2712F/281B/ACIT/CC/KLM/18-19 DT. 17/09/18 PERTAINING TO PROPERTIES OF THE PETITIONER COVERED BY DOCUMENT NO.944/15 & OTHER. EXHIBIT P14 A TRUE COPY OF THE ORDER BEARING NO.DDIT/INV/KLM/MKR/17-18 DT. 03/10/17 PERTAINING TO THE PROPERTIES AT BANGALORE COVERED BY DOCUMENT NO. EXHIBIT P14(A) A TRUE COPY OF THE ORDER BEARING NO.DDIT/INV/KLM/MKR/17-18 DT. 03/10/17 PERTAINING TO THE PROPERTIES AT BANGALORE COVERED BY DOCUMENT NO. EXHIBIT P14(B) A TRUE COPY OF THE ORDER BEARING NO.DDIT/INV/KLM/MKR/17-18 DT. 03/10/17 PERTAINING TO THE PROPERTIES AT BANGALORE COVERED BY DOCUMENT NO. EXHIBIT P15 THE ACKNOWLEDGMENT OF DECLARATION U/S 183 OF THE FINANCE ACT, 2016 WHICH INCLUDES THE DESCRIPTION OF THE PROPERTIES. EXHIBIT P16 THE DETAILS OF THE PAYMENT EFFECTED ON VARIOUS DATES, BY THE PETITIONER AND OTHER FAMILY MEMBERS.

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